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American Public Transportation Association

 Chairman Waxman of House Energy and Commerce Committee on Direct Emission Allowances for Transportation in the American Clean Energy and Security Act (ACESA), H.R. 2454


The Honorable Henry A. Waxman
House Committee on Energy and Commerce
2125 Rayburn House Office Building
Washington, DC 20515

(Download document in Adobe PDF format)

Dear Chairman Waxman:

The American Public Transportation Association (APTA) is very disappointed that H.R. 2454, the “American Clean Energy and Security Act” (ACESA), as introduced last week provides investment and transition assistance to numerous private industries, while the energy savings and emissions reductions from public transportation systems across America are completely overlooked. APTA strongly supports the efforts of your committee to develop comprehensive energy and climate change legislation, and we do not question the need to provide transition assistance to consumers, particularly low-income households, and critical domestic industries. However, ACESA in its present form fails to direct emission allowances to the transportation sector in an effective and sustainable manner. Congress shouldn’t miss this opportunity to make a long-term investment in a sustainable future by expanding public transportation services.

  • Public transportation use last year prevented the emission of more than 37 million metric tonnes of carbon dioxide. Those emissions savings are equivalent to the electricity used by 4.9 million households. Our nation’s transportation system produces one-third of all carbon dioxide (CO2) emissions in the U.S., and transportation is the fastest growing domestic source of greenhouse gas emissions, yet public transportation receives zero allowance value in ACESA.

    In contrast, the electricity sector will receive up to 35 percent of ACESA annual allowances.

  • Public transportation use in America saves 4.2 billion gallons of fuel each year and helps Americans reduce their commuting costs by escaping the high costs of gasoline and car ownership. In fact, riding public transportation can save an individual an average of $8,691 a year based on recent average gas and parking prices, yet public transportation receives zero allowance value in ACESA.

    In contrast, oil refineries will receive up to 2 percent of ACESA annual allowances.

  • Expanding public transportation is a proven strategy to make our transportation system more efficient and our roads less congested. Transit use saves more than 541 million hours in travel time and hundreds of millions of gallons of gasoline by preventing congestion each year. According to the Center for Clean Air Policy, growth in vehicle travel will negate much of the emission savings from improved vehicle economy and new fuels. Even with a fully electrified transportation system, public transportation will be needed to fight congestion and expand mobility, yet public transportation receives zero allowance value in ACESA.

    In contrast, the automotive industry will receive up to 3 percent of ACESA annual allowances to develop advanced automobile technologies.

APTA applauds the inclusion of emissions reduction goals for the transportation sector (Sec. 222, Greenhouse Gas Emissions Reductions Through Transportation Efficiency). However, new planning requirements will be hollow without significant investment in emission-reducing transportation infrastructure that complements energy-efficient community design.

A cap-and-trade program with investment in public transportation will produce more emissions savings and greater domestic job creation. Every $1 billion invested in federally aided public transportation capital projects supports approximately 30,000 jobs. We hope that future versions of ACESA will include substantial new investment in public transportation.

We appreciate your consideration of our views on ACESA, and we look forward to working with you as the Committee advances this vital legislation. If you have any questions, please have your staff contact Homer Carlisle of APTA's Government Affairs Department at (202) 496-4810 or email Thank you.

Sincerely yours,

William Millar Signature

William Millar

cc: Members of the Committee on Energy and Commerce

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